Putnam v. County of Steuben
This case involves an appeal from a judgment entered upon a jury verdict in favor of plaintiffs on their cause of action for malicious prosecution. The defendant appealed the judgment, challenging the liability verdict and the award of damages. The Appellate Division affirmed the trial court's denial of the defendant's motion to set aside the liability verdict, concluding that the jury rationally found the defendant's employees acted with reckless disregard for the plaintiff's rights by initiating a criminal prosecution without probable cause. Additionally, the court granted the plaintiffs' cross-appeal, determining that the lower court erred in setting aside the damages award, as damages for malicious prosecution can include those for arrest and imprisonment, and no false arrest claim was present to necessitate a separate instruction on avoiding duplicate awards. The judgment was unanimously affirmed without costs, and the order was modified to deny the defendant’s postjudgment motion in its entirety.